Duties and Reporting

AIFMD reporting obligation

These are:
- Submitting the manager's annual AIFMD report
- Submitting the annual AIFMD report of the AIFs under management

The legal obligation to provide AIFMD reports exists from the first quarter after the effective date of an AIF(M), and lasts up to and including the last reporting period in which an AIF(M) is active. The reporting period for AIFM registration managers will always be for the entire year.

As an example, an AIF(M) with an effective date of 1 January 2020, an end date of 1 January 2021 and an annual reporting frequency must provide the following AIFMD reports: X2-2020 (for the period 1/1/2020-31/12/2020) and Y1-2021 (for the period 1/1/2021-31/12/2021). The AFM uses the date of registration and deletion from its register as the effective date and end date. You can avoid being unjustly imposed a reporting obligation by deregistering the AIF(M) in question in the AFM Portal in a timely manner.

In addition, the AFM, together with ESMA, periodically checks the data quality of the submitted reports in the context of the Data Quality Engagement Framework. This DQEF audit checks the last submitted report of the calendar year (Q4, H2, Y1 or X2) and takes place annually in April, June, and October. You may then receive a request to submit a re-report. More information about this can be found in this sector letter.

File format of the reports

The AIFMD reports must be submitted in XML format, any other format will not be accepted. It is important that you submit a separate XML file for each reporting obligation that is open in the AFM portal containing only the data for that obligation. This can be a report for the manager or each individual fund, where each sub-fund counts as an individual fund. 

 

1. The XML that needs to be filled in and converted is done using the ESMA reporting template: 2013-1359_consolidated_aifmd_reporting_template-v1.1_revised.xlsx containing the templates for both the AIFM and AIF (in tabs). The explanation of which values are allowed can be found in the technical guidance, which can also be found on the ESMA website: https://www.esma.europa.eu/sites/default/files/2013-1358_aifmd_reporting_it_technical_guidance-revision4.zip.
2. The template must be rewritten to XML with the Schema: AIFMD - Reporting - XML documents - V1.2 [updated]. The XSD files in this zip file are the 'key' or 'grammar' for the XML files. In the XML files, the first line refers to the XSD files (for the AIFM reports to the file AIFMD_DATMAN_V1.2 and for AIFs it is AIFMD_DATAIF_V1.2).
3. Fields such as AIF and AIFM national code can be found in the AFM Portal. Here you will also find the reporting obligations. As a director, you can create an account and link it to the existing manager. 

 If you are unable to get the files in the right format, there is software available to help you with this and there are parties in the market that can help you with the conversion and delivery.

Turnaround time of the validation of the reports

Status updates are only visible in the AFM portal after the user has pressed F5 to refresh the page. This also applies if multiple reports are uploaded at the same time. The AFM validation of a submitted report normally takes only a few minutes. The lead time of the ESMA validation can vary greatly; from approximately 5 minutes to more than 24 hours.

The turnaround time is often shorter for AIFM reports and at the beginning of the delivery period and in the evening, night or early morning, but especially for AIF reports it can be considerably longer at the end of the delivery period and in the late morning or afternoon. This is probably due to the queue in which deliveries from all over Europe end up at ESMA and because many managers deliver at the same time.